Part 2 of your Traceability Toolkit. Technology, Transformation, and Exemptions. The Food Traceability Rule offers flexibility in how records are kept and clarifies exemptions for food transformation within your establishment.
Transformation and Direct Sales to Consumers
One key clarification for RFEs and restaurants concerns food transformation (e.g., chopping produce, preparing a meal) and direct sales:
You are not required to keep transformation KDEs for foods you do not ship—meaning foods you sell or send directly to consumers (like a fresh salad prepared in your kitchen and sold to a customer).
However, if you operate a central kitchen that transforms food and then ships it to another business (like a satellite restaurant or RFE), that central kitchen must keep the required transformation records.
Recordkeeping Format and Technology
The FDA does not require a specific application or technology for maintaining records. Records can be kept as:
Original paper or electronic records.
True copies (photocopies, scanned copies, pictures, etc.).
All records must be legible and stored to prevent deterioration or loss. Electronic records can even include valid, working links to the required information.
Electronic Spreadsheet Requirement and Exemption
While there’s no mandatory technology, the FDA may request traceability information in an electronic sortable spreadsheet during a public health threat.
Exemption: RFEs and restaurants with an average annual monetary value of food sold or provided of no more than $1,000,000 (adjusted for inflation) over the previous three-year period are exempt from the requirement to provide this electronic sortable spreadsheet upon request. However, they must still maintain all other required records.